Opinion
1841-21
03-23-2022
Marita Oglesbee & David Oglesbee Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On May 17, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. On December 29, 2021, respondent filed a supplement to his motion. In the motion, as supplemented, respondent seeks to dismiss this case on the ground that no notice of deficiency and no notice of determination concerning collection action was issued to petitioners for tax years 2012, 2013, and 2015, nor has respondent made any other determination with respect to those years that would confer jurisdiction on this Court. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction, as supplemented, is granted and this case is dismissed for lack of jurisdiction.